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NY L82211




January 27, 2005

CLA-2-82:RR:NC:N1:118 L82211

CATEGORY: CLASSIFICATION

TARIFF NO.: 6307.90.9889; 7326.90.8587; 8204.11.0060; 8205.40.0000; 8708.29.5060

Mr. Marc Torrence
V. Alexander and Company, Inc.
P. O. Box 291929
Nashville, TN 37229-1929

RE: The tariff classification of a plastic tool tray, lug wrench, torx screwdriver, and hook-and-loop strap from China.

Dear Mr. Torrence:

In your letter, dated January 14, 2005, on behalf of your client, Haley Industries, LLC, Nashville, TN, you requested a tariff classification ruling.

The merchandise is comprised of automotive jack assembly components. They are further described as follows:
hard plastic tool tray, part 84985-EA000 lug wrench, part 99545-7S000 jack rod 1, part 99552-7S200, steel jack rod 2, part 99552-7S010, steel torx screwdriver, part 99501-7Z000 hook-and-loop strap, part 13859B (cut to shape, made up article)

Rod 2 is inserted into rod 1, which, in turn, fits into the lug wrench to create a long handle for a scissor jack. The tray has fitted slots for the two jack rods and the torx screwdriver. There is a large slot in the center of the tray to accommodate an automobile jack and the lug wrench. At the factory in China, the two jack rods and the torx screwdriver will be inserted in the tray and the hook-and-loop strap will be attached. The lug wrench will be shipped with the tray in identical quantities.

After importation, the tray and lug wrench will be delivered to the auto manufacturer. There, the tray will be affixed under the seat of the automobile with 2 screws. An automotive jack will be placed in the tray, followed by the lug wrench and then the hook-and-loop strap will be tightened to secure those components to the tray. All of the components are utilized in conjunction with the jack except for the screwdriver, which is used to operate the sunroof of the vehicle.

Inasmuch as the imported item has products added after importation, it is not considered to be a set.

The applicable subheading for the plastic tool tray will be 8708.29.5060, Harmonized Tariff Schedule of the United States (HTS), which provides for parts and accessories of the motor vehicles of headings 8701 to 8705: other parts and accessories of bodies (including cabs): other: other: other. The rate of duty will be 2.5% ad valorem.

The applicable subheading for the lug wrench will be 8204.11.0060, HTS, which provides for hand-operated spanners and wrenches (including torque meter wrenches but not including tap wrenches); socket wrenches, with or without handles, drives or extensions; base metal parts thereof: hand-operated spanners and wrenches, and parts thereof: nonadjustable, and parts thereof: other (including parts). The rate of duty will be 9% ad valorem.

The applicable subheading for jack rods 1 and 2 will be 7326.90.8587, HTS, which provides for other articles of iron or steel: other: other: other: other: other. The rate of duty will be 2.9% ad valorem.

The applicable subheading for the torx screwdriver will be 8205.40.0000, HTS, which provides for handtools (including glass cutters) not elsewhere specified or included; blow torches and similar self-contained torches; vises, clamps and the like, other than accessories for and parts of machine tools; anvils; portable forges; hand- or pedal-operated grinding wheels with frameworks; base metal parts thereof: screwdrivers, and parts thereof. The rate of duty will be 6.2% ad valorem.

The applicable subheading for the hook-and-loop strap will be 6307.90.9889, HTS, which provides for other made up articles, including dress patterns: other: other: other: other: other. The rate of duty will be 7% ad valorem.

This ruling is being issued under the provisions of Part 177 of the Customs Regulations (19 C.F.R.).

A copy of the ruling or the control number indicated above should be provided with the entry documents filed at the time this merchandise is imported. If you have any questions regarding the ruling, contact National Import Specialist Kathy Campanelli at 646-733-3021.

Sincerely,

Robert B. Swierupski
Director,

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